Supply Chain Risk Identification and Assessment Annual Report

Identification of Suppliers of Precious Metals and Gemstones

As part of its due diligence procedures, Imperial-Deltah, Inc. has collected information on all suppliers of precious metals and gemstones for the period of January 1, 2024 to December 31, 2024. This entails Know Your Counterparty information that establishes beneficial ownership, banking information, anti-money laundering compliance, and locational information on the suppliers’ operations. Ownership and company information is cross-referenced against objective evidence, such as government-issued identification, public financial filings, business licenses, and other relevant documentation. Imperial-Deltah, Inc. also requires its suppliers to have a supply chain policy consistent with the OECD Guidance on Supply Chain Due Diligence as a condition of the ongoing business relationship and that any diamond vendors comply with the Kimberly Process Certification Scheme (KCPS), World Diamond Council System of Warranties (WDC SoW), and national law.

Assessment of Suppliers’ Due Diligence Practices

All Imperial-Deltah Inc.’s active suppliers of precious metals and gemstones conform to or exceed Imperial-Deltah Inc.’s requirements for KYC information and Supply Chain Due Diligence and transparency. In all cases, KYC information is complete and verified with additional evidence to support the veracity of the information collected. Furthermore, all suppliers of precious metals and gemstones have a Supply Chain Due Diligence policy and procedures in conformance with the OECD, including the requirements of Third-Party audit and Annual Reporting on their ongoing due diligence, which are reviewed by Imperial-Deltah Inc.’s Compliance Department alongside its CAHRA identification protocol.

Management Structure and Responsibilities for Supply Chain Due Diligence Risk Identification

Organizational Hierarchy

1. Executive Management
   • Responsibilities:
     • Provide strategic oversight and set risk management goals.
     • Approve risk management policies and resource allocation.
     • Ensure alignment of due diligence processes with business objectives.
     • Works with legal consultants to ensure legality of internal  policy and procedures
     • Review supplier contracts for clauses that manage risk exposure.

        2. Compliance Officer

• • Responsibilities:
    • Oversee the risk identification and mitigation process.
    • Review risk reports and escalation procedures.
    • Monitor the implementation of corrective actions.
    • Ensure integration of due diligence activities across the supply chain.
    • Coordinate between departments to ensure comprehensive risk assessment.
    • Develop and implement risk mitigation strategies.

    3. Purchasing Manager

• • Responsibilities:
    • Collaborate in identifying vendor-related risks
    • Perform supplier evaluations and audits.
    • Engage in due diligence for new suppliers to assess potential risks.
    • Maintains supplier information on the Approved Supplier List

4. Operations
   • Responsibilities:
     • Identify operational risks related to logistics, warehousing, and inventory management.
     • Report issues that may affect supply chain continuity and performance.
5. IT
   • Responsibilities:
     • Identify risks related to data security and technology infrastructure.
     • Ensure proper risk identification related to third-party systems and cyber threats.
6. Risk and Internal Audit Team:
   • Responsibilities:
     • Conduct risk assessments and audits of the supply chain operations.
       
     • Identify gaps in the current due diligence process.

Risks Identified

No risks have been identified for the period of January 1, 2024 to December 31, 2024. This marks Imperial-Deltah Inc.’s second year of rigorous engagement with the Due Diligence program outlined in this report, and it will continue to review and assess its own due diligence practices for continued improvement.

Strategy to Respond to Identified Risks

 As there are no identified risks based on KYC, AML, and CAHRA Identification protocols for this period, this section is not applicable, but will be included in subsequent Annual Reports as necessary based on any identified risks for that period.

 

Supply Chain Policy

(Updated 2/10/2023)

Imperial-Deltah Inc. is a jewelry importer and manufacturer specializing in Cultured Pearls and Cultured Pearl Jewelry. This policy confirms Imperial’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

Imperial-Deltah Inc. is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

• respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Declaration on Fundamental Principles and Rights at Work;
• do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism.
• support transparency of government payments and rights-compatible security forces in the extractives industry.
• do not provide direct or indirect support to illegal armed groups;
• enable stakeholders to voice concerns about the jewelry supply chain; and
• are implementing the OECD 5-Step framework as a management process for risk based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others. Any business partners who do not share and support these same commitments will not be considered as an Approved Supplier of Imperial-Deltah, Inc. Interested parties may share their comments or complaints regarding Conflict-Affected High-Risk Areas (CAHRA) by contacting: compliance@imperialpearl.com. 

Regarding serious abuses associated with the extraction, transport or trade of diamonds, colored gemstones (including Cultured Pearls) Gold, Silver PGM

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

• torture, cruel, inhuman and degrading treatment.
• forced or compulsory labor;
• the worst forms of child labor;
• human rights violations and abuses; or
• war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in the above or are sourcing from, or linked to, any party committing these abuses.

 Regarding direct or indirect support to non-state armed groups

We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring Gold, Silver & PGM from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

• control mine sites, transportation routes, points where Gold, Silver & PGM are traded and upstream actors in the supply chain: or
• tax or extort money, or Gold, Silver & PGM at mine sites, along transportation routes or at points where Gold, Silver & PGM are traded, or from intermediaries, export companies or international traders.

We only sell or purchase diamonds/colored gemstones that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds, colored gemstones & cultured pearls from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

• control mine or harvest sites, transportation routes, points where diamonds, colored gemstones & cultured pearls are traded and upstream actors in the supply chain; or
• tax or extort money or diamonds, colored gemstones & cultured pearls at mine or harvest sites, along transportation routes or at points where diamonds, colored gemstones & cultured pearls are traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described above.

Regarding public or private security forces

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described above.

Regarding bribery and fraudulent misrepresentation of the origin of diamonds, colored gemstones, cultured pearls, Gold, Silver & PGM

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds, colored gemstones, cultured pearls, Gold, Silver & PGM, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds, colored gemstones, cultured pearls, Gold, Silver & PGM.

Regarding money laundering

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds, colored gemstones, cultured pearls, Gold, Silver & PGM

 

Signed/endorsed:

Jonathan Louttit

Chief Operating Officer